Last Updated May 12, 2023 – Ref: VMUS.May 2023.V1.0
Who We Are
Volta Medical, Inc. (“Volta Medical”) has a mission to develop digital health platforms and artificial
intelligence-powered tools and analytics that revolutionize interventional cardiac electrophysiology for the benefit of patients with cardiac arrhythmias. We are committed to respecting personal privacy and complying with all applicable privacy laws and regulations. This Privacy Statement describes Volta Medical’s policies and practices on the collection, use, disclosure, and storage of Personal Information of United States residents and our commitment to protecting it from unauthorized use or disclosure.
Applicability of This Privacy Statement
This Privacy Statement is intended for residents of the United States, including visitors to www.volta-medical.com (“Site”) and, where applicable, applies to Personal Information that Volta Medical obtains and processes other than through the Sites (for examples, see paragraph “How we use the information we collect“). Residents of other countries should refer to websites intended for their country of residence and the Privacy Statement provided for those countries.
Volta Medical is part of a global organization and any information that you provide or we collect, will be available to Volta Medical affiliates around the world. This means that your information may be transmitted to our affiliates and vendors located in a country other than the United States. However, regardless of the country to which your Personal Information is transferred, it will be protected in a manner consistent with the protections described in this Privacy Statement.
By using this Site, you consent to the collection, use, storage, and processing of your Personal Information in the United States and in any country to which we may transfer your Personal Information in the course of our business operations.
Where this Site offers links to other websites that are owned or controlled by third parties, this Privacy Statement will not apply once you move to the third-party website. We encourage you to review the privacy policies of any third-party sites prior to providing them with any of your personal information, as Volta Medical cannot accept responsibility for the privacy practices of any websites not controlled by us.
Please review this Statement carefully. To the extent permitted by applicable law, by providing us your Personal Information or otherwise interacting with us, you are agreeing to this Statement.
Information we collect on our Sites
This section describes information that individuals might choose to provide to us, as well as our practices for the automatic collection and use of certain information related to the use and navigation of our Sites.
Information you provide
We define Personal Information as information that can (directly or indirectly) identify, locate, or be used to contact you or communicate with you, such as your name, address, telephone number, e-mail address, characteristics, or descriptions (such as gender and date of birth), and other similar and associated information (“Personal Information”). Personal Information includes certain subsets of Personal Information that are considered “sensitive” pursuant to applicable laws, such as information about health or medical status, and healthcare products used or services received (“Sensitive Personal Information”).
In most cases, we collect Personal Information directly from you. We will ask you for Personal Information, for example, when you interact with us, such as a person seeking employment who may choose to apply for a job online or request additional information about job opportunities; or a health care professional who might ask that we send information about one or more of our products. Before providing Sensitive Personal Information to us, we urge you to carefully consider whether to disclose it. If you do provide Sensitive Personal Information to us, you are consenting to its use and disclosure for the purposes and in the manner described at the time of collection and as set forth in this Privacy Statement.
Information we collect automatically
Additionally, through your use of the Site, we collect information related to your use by automated means, such as the date and time of your visit, information about your device and device settings, and also the country, region, and time zone where your device is located, as well as information about your consent status to the use of cookies, and the URL from which the consent was submitted (collectively, “Usage Data”). Usage Data also includes the IP Address of the device you use to connect to the Internet, as well as an anonymous, random, and encrypted key value generated by our cookie management platform, CookieFirst. For your information, an IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. In certain circumstances, where we link Usage Data and Personal Information, Usage Data may be considered Personal Information. In particular, Usage Data allow us to identify the country you are visiting from, so that we may direct you automatically to the content that is appropriate for your country.
CookieFirst is provided By Digital Data Solutions BV, Plantage Middenlaan 42a, 1018 DH, Amsterdam, The Netherlands. You can visit the website of CookieFirst at: https://cookiefirst.com/.
Digital Advertising, Cookies and Other Data Collection Technologies
When you use our Sites, we collect different types of Usage Data by automated means, using technologies such as APIs, web services, scripts, cookies, pixels, tags, web beacons, browser analysis tools, and server logs. We may also use vendors, such as CookieFirst, to place cookies and collect data to enable certain services we use, personalization, site analytics to measure and improve the performance of our Sites and security services, and the data may be disclosed to our vendors for these purposes.
Other data may be disclosed to vendors providing additional services integrated into our Sites, including performance monitoring, user experience components such as user interface frameworks, images and web fonts, and maps.
When you use the Site, we may place cookies on your computer. Cookies are small text files that websites or mobile apps send to your computer or other Internet-connected device to uniquely identify your browser or to store data or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud.
You can control many of the cookies through the CookieFirst platform, which appears when you first visit the Site and can also be accessed during your visit through the lower left-hand corner of the webpage. The Cookie First platform describes the different types of cookies, and whether they can be disabled.
You can also opt-out of receiving targeted advertising from Network Advertisers by going to www.networkadvertising.org. In addition, the Digital Advertising Alliance maintains a web site where consumers can opt out from receiving interest-based advertising from some or all of the network advertising companies participating in the program (www.AboutAds.info/choices).
In many cases, the data we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. However, under some privacy and data protection laws, this data could be considered Personal Information. This Privacy Statement governs how we use this data when it is considered your Personal Information.
Information we collect outside this Site
Volta Medical may also Personal Information in ways other than through this Site. For example, Volta Medical collects information about customers and potential customers and their representatives - such as contact information, financial/billing information, and any other information that is provided to us during the course of doing business. For example, physicians notify us of complaints or adverse events with our products. We maintain records of purchases by our physician customers as well as our interactions with them, including their attendance at educational and other events we host.
We also collect information from our vendors, suppliers, consultants, professional advisors, and other third parties for the purposes of managing and operating our business. For example, we will collect business contact information, financial information, and other information necessary to engage our suppliers and other business partners and to evaluate their performance.
Volta Medical protects all Personal Information received by us, whether it is received through the Site or otherwise.
How we use the information we collect
Volta Medical may use Personal Information for its business, operational, and legal purposes, including but not limited to:
● Responding to your inquiry, request or job application, and to provide you with information and access to resources that you have requested from us;
● Improving the content and usability of the Site, system administration, and security;
● Providing, operating and maintaining the Site;
● Providing you with general information about certain disease or health conditions, and about Volta Medical’s products and services;
● Processing and completing transactions;
● Managing customer relationships, including providing customer service and support and responding to queries or complaints;
● Creating de-identified data so that it is no longer Personal Information;
● Conducting research and development to improve our products and services;
● Assessing credit or financial risks arising from any existing or prospective business relationship; or
● For other legitimate business purposes.
You will be able to “unsubscribe” from Volta Medical email communications by following the instructions provided at the time you sign up for the communications or that are included in such communications.
We may use the Usage Data we and our partners collect during your future visits. This information allows us to direct you to specific content on the Sites that may be of interest and to remember your computer/device the next time you visit.
Disclosure of information to third parties
Although Volta Medical does not directly sell, rent, or loan personal information, we may share your information with companies, organizations and individuals outside of Volta Medical or its affiliates as described below.
We may share Personal Information with our service providers, who are bound by contract to protect Personal Information and only use it as specified in the contract. As one example, we share Personal Information with service providers who provide data processing or purchase fulfillment for us.
We may also disclose Personal Information for legal or law enforcement purposes. This includes, for example, disclosures made in response to a court order or a subpoena, or in response to a law enforcement agency's request. We also may disclose such information to third parties:
● where we believe it is necessary for prevention of fraud or to investigate, prevent, or take action regarding illegal activities,
● in relation to violations of our terms of use or other rules,
● to protect the rights and/or safety of others, or to protect Volta Medical’s rights,
● as needed to support good corporate governance, and
● as otherwise required by law.
Please note that we may also disclose data about you that is not personally identifiable. For example, we may publish reports that contain aggregate and statistical data about our customers.
How we protect information
Volta Medical complies with applicable laws and regulations, and has implemented reasonable physical, technical, and administrative safeguards designed to protect Personal Information from loss, misuse, alteration, theft, unauthorized access, and other unauthorized disclosure. However, despite these efforts, we are not able to guarantee that personal information will always remain completely safe.
We are not responsible for any interception or interruption of any communications or for changes to or losses of data through the internet.
How long we retain personal information We retain information as long as it is necessary and relevant for our business, operational, and legal purposes. This includes compliance with applicable laws, dispute resolution, troubleshooting, fraud prevention, troubleshoot problems, legal investigations, or other actions permitted by law. When your Personal Information is no longer needed for Volta Medical’s business, operational, and legal purposes, we dispose of it subject to applicable law.
The planned retention period foreach cookie is described in the CookieFirst platform accessible here.
Your privacy choices
In your use of this Site, you will be given opportunities to make choices about the data we receive and how we use it.
Do Not Track signals and Global Privacy Control. Some web browsers incorporate other "do-not-track" (“DNT”) or similar features that signals to websites with which the browser communicates that a visitor does not want to have their online activity tracked. Volta Medical does not currently respond toDNT signals; however, Volta Medical does not track your activity across non-Volta Medical websites.
Opting out of communications. If you provide Personal Information to us, we may from time to time send you communications, including electronic communications about products or services. You may unsubscribe to such communications by following the instructions that are included in the communication.
Cookies. The CookieFirst platform embedded on the Site allows you to change your cookie settings any time you visit the Site. In addition, your Web browser settings allow you to change your cookie settings. Please be aware that the Site functions may not work well if you choose to reject some cookies. You also have the options described above in the Digital Advertising, Cookies and Other Data Collection Technologies section of this Privacy Statement.
Data privacy rights - residents of U.S. states with privacy laws.
Residents of U.S. states with comprehensive privacy laws should be aware that the nature of Volta Medical’s business takes it outside the scope of those laws. However, Volta Medical does not sell or derive revenue from Personal Information.
Children's privacy
Volta Medical does not intend to collect Personal Information from children under age 13, without consent from the child’s parent or legal guardian. We do not share Personal Information of anyone under 13 years of age with anyone outside of Volta Medical or its affiliates (except where required by law, and to our agents who have committed to maintain data privacy).
If you are under the age of 13, do not provide any Personal Information to us, unless you have the agreement of your parent or guardian. If you are a parent or guardian, and you believe that your child has submitted Personal Information which you would like removed, please contact Volta Medical at the address listed below.
If you have concerns about your personal information
If you have any questions about this Privacy Statement or about your personal information, you may contact us as follows:
dpo@volta-medical.com. Please be sure to include your name, postal address (only if you want a response by postal mail), and email address. If we do not receive a postal address, we will respond by e-mail.
Changes to our privacy statement
We will use Personal Information in accordance with the Privacy Statement in place at the time the information was collected. We may update this Privacy Statement from time to time, and the updated statement will be available on this page.
Revised May 12, 2023
